As mentioned in our previous post, the Cyprus DAC6 Guidance has been with us since October 2021, but has to date been available only in Greek (publicly at least). A copy of the version from the Official Journal in Greek is here.

However, further to strong client and industry demand, we, Harneys, have translated and vetted an English version of the Cyprus DAC6 Guidance. We are today publishing an unofficial translation of the Decree in English on this blog.

The Cyprus DAC6 Guidance provides incredibly useful interpretive guidance for anyone trying to make sense of DAC6 in practice. It covers for example:

• Detail on the distinction between and meaning of a primary and secondary intermediary, as relevant to the Cyprus market
• An understanding of the main benefit test (MBT), in particular the non-application of the MBT in respect of non-Union tax benefits
• A breakdown of DAC6 hallmarks one by one
• An outline of the reporting mechanism
• The final position of the application of the legal professional privilege (LPP) safe-harbour.

The Harneys unofficial translation of the Cyprus DAC6 Guidance in English is here.